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2015 RI NG Program Evaluation - ri2015ngprogramevaluation (Rhode Island; Natural Gas State Program Evaluation)
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RI NG Program Evaluation, 2015, page 1Official PDF1200 New Jersey Avenue SE Washington DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 2015 Gas State Program Evaluation for RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS Document Legend PART: O -- Representative Date and Title Information A -- Progress Report and Program Documentation Review B -- Program Inspection Procedures C -- Program Performance D -- Compliance Activities E -- Incident Investigations F -- Damage Prevention G -- Field Inspections H -- Interstate Agent State (If Applicable) I -- 60106 Agreement State (If Applicable) DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 1#
RI NG Program Evaluation, 2015, page 22015 Gas State Program Evaluation -- CY 2015 Gas State Agency: Rhode Island Rating: Agency Status: Date of Visit: 09/12/2016 - 09/16/2016 Agency Representative: Don Ledversis, Gas Pipeline Safety Engineer PHMSA Representative: Patrick Gaume Commission Chairman to whom follow up letter is to be sent: Name/Title: Mr. Macky McCleary, Administrator Agency: Rhode Island Division of Public Utilities and Carriers Address: 89 Jefferson Blvd City/State/Zip: Warwick, Rhode Island 02888 60105(a): Yes 60106(a): No Interstate Agent: No INSTRUCTIONS: Complete this evaluation in accordance with the Procedures for Evaluating State Pipeline Safety Program. The evaluation should generally reflect state program performance during CY 2015 (not the status of performance at the time of the evaluation). All items for which criteria have not been established should be answered based on the PHMSA representative's judgment. A deficiency in any one part of a multiple part question should be scored as needs improvement. Determine the answer to the question then select the appropriate point value. If a state receives less then the maximum points, include a brief explanation in the space provided for general comments/regional observations. If a question is not applicable to a state, select NA. Please ensure all responses are COMPLETE and ACCURATE, and OBJECTIVELY reflect state program performance. Increasing emphasis is being placed on performance. This evaluation together with selected factors reported in the state's annual progress report attachments provide the basis for determining the state's pipeline safety grant allocation. Field Inspection (PART G): The field inspection form used will allow different areas of emphasis to be considered for each question. Question 13 is provided for scoring field observation areas. In completing PART G, the PHMSA representative should include a written summary which thoroughly documents the inspection. Scoring Summary PARTS Possible Points Points Scored A Progress Report and Program Documentation Review 10 9 B Program Inspection Procedures 13 13 C Program Performance 48 46 D Compliance Activities 15 15 E Incident Investigations 10 10 F Damage Prevention 8 8 G Field Inspections 12 12 H Interstate Agent State (If Applicable) 0 0 I 60106 Agreement State (If Applicable) 0 0 TOTALS 116 113 State Rating................................................................................................................................................... 97.4 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 2#
RI NG Program Evaluation, 2015, page 3PART A - Progress Report and Program Documentation Review Points(MAX) Score 1 Accuracy of Jurisdictional Authority and Operator/Inspection Units Data - Progress Report Attachment 1 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A1. Yes. Attachment 1 is consistent with Attachment 3 and Attachment 8. 1 1 2 Review of Inspection Days for accuracy - Progress Report Attachment 2 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A2. Yes. Attachment 2 is consistent with the time sheets 1 1 3 Accuracy verification of Operators and Operators Inspection Units in State - Progress 1 0.5 Report Attachment 3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A3. NI 0.5 of 1 point. 2 LNG Units that were assigned to 'National Grid' opid 35635, should be assigned to 'Niagra Mohawk Power Corp', opid 13480. Attachment 3 was revised. 4 Were all federally reportable incident reports listed and information correct? - Progress Report Attachment 4 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A4 Yes. There was one significant incident in 2015. A full on-site inspection was performed. 1 1 5 Accuracy verification of Compliance Activities - Progress Report Attachment 5 1 0.5 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: NI, 0.5 of 1 pt. A violation of State Regulations was incorrectly reported on Attachment 5. Attachment 5 will be revised. 6 Were pipeline program files well-organized and accessible? - Progress Report Attachment 6 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: A6. Yes. The files are in Don's office or in the database. Most official files are still paper. 2 2 7 Was employee listing and completed training accurate and complete? - Progress Report Attachment 7 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A7. Yes. Don's time is consistent with his time sheets and his training is in agreement with TQ records. 1 1 8 Verification of Part 192,193,198,199 Rules and Amendments - Progress Report Attachment 8 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A8. Yes. RI State Laws authorize automatic adoption of updates of named regulations. 1 1 9 List of Planned Performance - Did state describe accomplishments on Progress Report in detail - Progress Report Attachment 10 1 1 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 3#
RI NG Program Evaluation, 2015, page 4Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: A9. Yes; Attachment 10 was properly completed. The strong effort to replace bare steel & cast iron continues. Low pressure systems, from 0 to 25 psig, are being replaced with PE to reduce water intrusion into the distribution systems. Damage Prevention efforts are continuing and excavation damages dropped for 4 years in a row with an uptick in 2015. Line hits have dropped from 166 in 2010 to 114 in 2014 up to 165 in 2015. 10 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: A10. Attachments 3 & 5 needed revisions. The strong effort to replace bare steel & cast iron continues. Low pressure systems, from 0 to 25 psig, are being replaced with PE to reduce water intrusion into the distribution systems. Damage Prevention efforts are continuing. Total points scored for this section: 9 Total possible points for this section: 10 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 4#
RI NG Program Evaluation, 2015, page 5PART B - Program Inspection Procedures Points(MAX) Score 1 Standard Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: B1. Yes. See Procedure Manual, Book 1, Sections IV & V, pages 8-15. 2 2 2 IMP and DIMP Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B2. Yes. See Procedure Manual, Book 1, Sections IV & V, pages 8-15 1 1 3 OQ Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B3. Yes. See Procedure Manual, Book 1, Sections IV & V, pages 8-15 1 1 4 Damage Prevention Inspection procedures should give guidance to state inspectors that insure consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post- inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B4. Yes. Is part of the Standard Inspection. See page 6 192.614. "Damage Prevention". 1 1 5 Any operator training conducted should be outlined and appropriately documented as 1 1 needed. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B5. Yes. See Procedure Manual, Book 1, Sections IV & V, pages 8-15. Training is also done during the Pipeline Safety Seminars 1/yr, Managing Underground Safety Training Seminars 2/yr, and during all inspections. 6 Construction Inspection procedures should give guidance to state inspectors that insure 1 1 consistency in all inspections conducted by the state? The following elements should be addressed at a minimum - pre-inspection activities, inspection activities, post-inspection activities. Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: B6. Yes. See Procedure Manual, Book 1, Sections IV & V, pages 8-15, specifically page 12. RIDPUC uses the RI plastic construction form, the RI steel construction form and/or the federal Form 5-EVALUATION REPORT OF GAS PIPELINE & COMPRESSOR STATION CONSTRUCTION as needed. DUNS: 623014990 2015 Gas State Program Evaluation 7 Does inspection plan address inspection priorities of each operator, and if necessary each 6 6 unit, based on the following elements? Yes = 6 No = 0 Needs Improvement = 1-5 a. Length of time since last inspection (Within five year interval) Yes No Needs Improvement Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 5#
RI NG Program Evaluation, 2015, page 6b. Operating history of operator/unit and/or location (includes leakage, incident and compliance activities) Yes No Needs Improvement c. Type of activity being undertaken by operators (i.e. construction) Yes No Needs Improvement d. Locations of operators inspection units being inspected - (HCA's, Geographic areas, Population Density, etc) Yes No Needs Improvement e. Process to identify high-risk inspection units that includes all threats - (Excavation Damage, Corrosion, Natural Forces, Outside Forces, Material and Welds, Equipment, Yes No Needs Improvement Operators and any Other Factors) f. Are inspection units broken down appropriately? Yes No Needs Improvement Evaluator Notes: B7. Yes. See Procedure Manual, Book 1, Section IV, pages 8-9. The main point is that every operator is seen every year. 8 General Comments: Info Only = No Points Evaluator Notes: B8. The Procedure Manual is well written and can serve as a ready reference. Info Only Info Only Total points scored for this section: 13 Total possible points for this section: 13 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 6#
RI NG Program Evaluation, 2015, page 7PART C - Program Performance Points(MAX) Score 1 Was ratio of Total Inspection person-days to total person days acceptable? (Director of State Programs may modify with just cause) Chapter 4.3 Yes = 5 No = 0 A. Total Inspection Person Days (Attachment 2): 117.00 B. Total Inspection Person Days Charged to the Program (220 X Inspection Person Years) (Attachment 7): 220 X 0.95 = 209.00 Ratio: A / B 117.00 / 209.00 = 0.56 If Ratio >= 0.38 Then Points = 5, If Ratio < 0.38 Then Points = 0 Points = 5 Evaluator Notes: C1. Yes. 117 AFOD 0.95 person-year 117/(.95*220)=.5598, >.38 okay. 5 5 2 Has each inspector and program manager fulfilled the T Q Training Requirements? (See 5 5 Guidelines Appendix C for requirements) Chapter 4.4 Yes = 5 No = 0 Needs Improvement = 1-4 a. Completion of Required OQ Training before conducting inspection as lead? Yes No Needs Improvement b. Completion of Required DIMP*/IMP Training before conducting inspection as lead? *Effective Evaluation CY2013 Yes No Needs Improvement c. Root Cause Training by at least one inspector/program manager Yes No Needs Improvement d. Note any outside training completed Yes No Needs Improvement e. Verify inspector has obtained minimum qualifications to lead any applicable standard inspection as the lead inspector. Yes No Needs Improvement Evaluator Notes: C2. Yes to all. Don needs one course to be qualified to lead a TIMP, but has never lead a TIMP inspection. No outside training other than OJT, Seminars, and Conferences. 3 Did state records and discussions with state pipeline safety program manager indicate adequate knowledge of PHMSA program and regulations? Chapter 4.1,8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C3. Yes. No issues. 2 2 4 Did state respond to Chairman's letter on previous evaluation within 60 days and correct or address any noted deficiencies? (If necessary) Chapter 8.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C4. Yes. Response was in about 46 days; from 12/11/15 to 1/26/16. All six issues were addressed. 2 2 5 Did State hold PHMSA TQ Seminar in Past 3 Years? Chapter 8.5 Yes = 2 No = 0 Evaluator Notes: C5. Yes. The most recent Seminar was in Oct 20-21, 2015 in Mt. Snow, VT. 2 2 6 Did state inspect all types of operators and inspection units in accordance with time intervals established in written procedures? Chapter 5.1 Yes = 5 No = 0 Needs Improvement = 1-4 5 4 Evaluator Notes: C6. NI. 4 of 5 points. ---The Transmission inspection issues have been addressed by having the operator, National Grid, DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 7#
RI NG Program Evaluation, 2015, page 8enter into a Compliance Order Agreement to re-work the city gates and convert the short sections of transmission line into distribution main lines. Work is in progress, 9/13/16, at the 1st regulator station, a scheduled completion date of October 31st is set for the 2nd regulator station, (known as Phase 1), and a completion date of May 5, 2017 is set for the 3rd regulator station, (known as Phase 2).. ---The single LDC, National Grid, has been DIMP inspected with yearly updates. The 43 MM & LPG operators were notified about DIMP in 2011 & had DIMP explained. In July, 2015, RIDPUC agreed to start doing 10 DIMP inspections/yr, risk ranked, and write the plan into his procedures. In the last half of 2015 & the first half of 2016, RI has performed 21 DIMP inspections and hopes to complete the remaining 22 DIMP inspections by July 2017. This response meets the agreement made during the July, 2015 Program Evaluation. ---NI. PAPEI inspections still NI: The single LDC, National Grid, was inspected for PAPEI & it was loaded into the database. In July, 2015, RIDPUC agreed to start doing 15 PAPEI inspections/yr, risk ranked, and write the plan into his procedures. In the last half of 2015 & the first half of 2016, RI has performed 21 PAPEI inspections and hopes to complete the remaining 22 PAPEI inspections by July 2017. This response meets the agreement made during the July, 2015 Program Evaluation. However, it was discovered that RI has never downloaded the PAPEI database and therefore has not been able to upload the PAPEI inspections into the federal database. 7 Did inspection form(s) cover all applicable code requirements addressed on Federal 2 2 Inspection form(s)? Did State complete all applicable portions of inspection forms? Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C7. Yes. The information reviewed showed no issues. PHMSA form 2 is used on the National Grid inspection. The federal forms are used for all types of inspections except for Construction. The State Construction Forms are adequate and the Federal Form is referenced as needed. 8 Did the state review operator procedures for determining if exposed cast iron pipe was examined for evidence of graphitization and if necessary remedial action was taken? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 C8. Yes. There is a Cast iron encroachment & replacement program in place with National Grid, no issues. 9 Did the state review operator procedures for surveillance of cast iron pipelines, including appropriate action resulting from tracking circumferential cracking failures, study of leakage history, or other unusual operating maintenance condition? (Note: See GPTC Appendix G-18 for guidance) (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: 1 1 C9. Yes. There is a Cast iron encroachment & replacement program in place with National Grid, no issues. 10 Did the state review operator emergency response procedures for leaks caused by excavation damage near buildings and determine whether the procedures adequately address the possibility of multiple leaks and underground migration of gas into nearby buildings Refer to 4/12/01 letter from PHMSA in response to NTSB recommendation P-00-20 and P-00-21? (NTSB) Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C10. Yes. This is verified on PHMSA form 2 inspection checklist. 1 1 11 Did the state review operator records of previous accidents and failures including reported third party damage and leak response to ensure appropriate operator response as required by 192.617? Chapter 5.1 Yes = 1 No = 0 Evaluator Notes: C11. Yes. 192.617 is covered on inspection checklist. 1 1 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 8#
RI NG Program Evaluation, 2015, page 912 Has the state reviewed Operator Annual reports, along with Incident/Accident reports, for accuracy and analyzed data for trends and operator issues? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: C12.Yes. The only applicable operator is National Grid. Trends and data are being adequately addressed. No issues. 13 Did state input all applicable OQ, DIMP/IMP inspection results into federal database in a timely manner? This includes replies to Operator notifications into IMDB database. Chapter 5.1 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C13. NI. 1 of 2 points. Zero DIMPs have been uploaded into the Federal database. 2 1 14 Has state confirmed intrastate transmission operators have submitted information into NPMS database along with changes made after original submission? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C14. Yes. It is only 160' total in 3 sites. It is in NPMS and on the annual report. 1 1 15 Is the state verifying operators are conducting drug and alcohol tests as required by 2 2 regulations? This should include verifying positive tests are responded to in accordance with program. 49 CFR 199 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C15. Yes, there is only one LDC in RI, National Grid, and the D&A long form is used every year during the annual HQ inspection. The other 43 operators are MM & LPG companies. 16 Is state verifying operators OQ programs are up to date? This should include verification 2 2 of any plan updates and that persons performing covered tasks (including contractors) are properly qualified and requalified at intervals determined in the operators plan. 49 CFR 192 Part N Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C16. Yes. The OQ plan for National Grid is up to date. all ok. The MM & LPG operators are guided into acceptable OQ Plans and provided with a list of consultants who are compliant with those OQ Plans. 17 Is state verifying operator's gas transmission integrity management programs (IMP) are 2 2 up to date? This should include a previous review of IMP plan, along with monitoring progress on operator tests and remedial actions. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart 0 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: C17.Yes. The TIMP issue has been addressed by having the operator, National Grid, enter into a Compliance Order Agreement to re-work the city gates and convert the short sections of transmission line into distribution main lines. Work is in progress, as of 9/13/16, at the 1st regulator station; a scheduled completion date of October 31st is set for the 2nd regulator station, (known as Phase 1); and a completion date of May 5, 2017 is set for the 3rd regulator station, (known as Phase 2). 18 Is state verifying operator's gas distribution integrity management Programs (DIMP)? This should include a review of DIMP plans, along with monitoring progress. In addition, the review should take in to account program review and updates of operators plan(s). 49 CFR 192 Subpart P DIMP ? First round of program inspections should have been complete by December 2014 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 C18. Yes. The DIMP is reviewed annually for the LDC, and a plan is in place for DIMP reviews of MM & LPG operators. DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 9#
RI NG Program Evaluation, 2015, page 1019 Is state verifying operators Public Awareness programs are up to date and being followed. State should also verify operators have evaluated Public Awareness programs for effectiveness as described in RP1162. 49 CFR 192.616 (I13-16) PAPEI Effectiveness Inspections should be conducted every four years per RP1162 Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 C19. Yes. The PAPEI is current for the LDC, and a plan is in place for PAPEI reviews of MM & LPG operators. 20 Does the state have a mechanism for communicating with stakeholders - other than state pipeline safety seminar? (This should include making enforcement cases available to public). Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C20. Yes. Public records are accessible, web-site is in place for docketed information. See http://www.ripuc.org/utilityinfo/natgas/Pipeline_safety.html 1 1 21 Did state execute appropriate follow-up actions to Safety Related Condition (SRC) Reports? Chapter 6.3 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C21. NA. None in CY 2013, 14, or 2015. 1 NA 22 Did the State ask Operators to identify any plastic pipe and components that has shown a record of defects/leaks and what those operators are doing to mitigate the safety concerns? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C22. Yes. No issues and National Grid participates in PPDC. 1 1 23 Did the state participate in/respond to surveys or information requests from NAPSR or PHMSA? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: C23. Yes. RI responds to all NAPSR & PHMSA requests. 1 1 24 If the State has issued any waivers/special permits for any operator, has the state verified conditions of those waivers/special permits are being met? This should include having the operator amend procedures where appropriate. No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: C24. NA. RI has not issued any waives/special permits that are currently active. 1 NA 25 Did the state attend the National NAPSR Board of Directors Meeting in CY being 1 1 evaluated? No = 0 Needs Improvement = .5 Yes = 1 Evaluator Notes: C25. YES. Don was able to attend the Nat'l NAPSR Meeting in Tempe,AZ. He is planning to attend the National NAPSR Meeting in Indianapolis, IN in 2016. 26 DUNS: 623014990 2015 Gas State Program Evaluation Discussion on State Program Performance Metrics found on Stakeholder Communication 2 2 site - http://primis.phmsa.dot.gov/comm/states.htm No = 0 Needs Improvement = 1 Yes = 2 a. Discussion of Potential Accelerated Actions (AA's) based on any negative trends Yes No Needs Improvement b. NTSB P-11-20 Meaningful Metrics Yes No Needs Improvement Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 10#
RI NG Program Evaluation, 2015, page 11Evaluator Notes: C26. YES. RI data appears to be accurate. Line hits per thousand were declining from 2010 to 2014, but had an uptick in 2015. RIDPUC accelerated the cast iron & bare steel removal to become a 20 year program for total removal from the State. It started in 2015 and will end in 2034. 27 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: C27. RIDPUC has started a plan to conduct all types of inspections and keep current with the inspections going forward. RIDPUC has addressed replacing the existing 160 feet of transmission with work in progress, as of 9/14/16, at the 1st regulator station; a completion date of October 31st for the 2nd regulator station, (known as Phase 1); and a completion date of May 5, 2017 for the 3rd regulator station, (known as Phase 2). RIDPUC has developed a plan with the State's LDC, National Grid, to replace 200 bare steel services most prone to corrosion due to a cluster survey of bare steel pipe. Total points scored for this section: 46 Total possible points for this section: 48 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 11#
RI NG Program Evaluation, 2015, page 12PART D - Compliance Activities Points(MAX) Score 1 Does the state have written procedures to identify steps to be taken from the discovery to 4 4 resolution of a probable violation? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Procedures to notify an operator (company officer) when a noncompliance is identified Yes No Needs Improvement b. Procedures to routinely review progress of compliance actions to prevent delays or breakdowns Yes No Needs Improvement Evaluator Notes: D1. Yes. The RIDPUC process rules are well established. 2 Did the state follow compliance procedures (from discovery to resolution) and adequately 4 4 document all probable violations, including what resolution or further course of action is needed to gain compliance? Chapter 5.1 Yes = 4 No = 0 Needs Improvement = 1-3 a. Were compliance actions sent to company officer or manager/board member if municipal/government system? Yes No Needs Improvement b. Document probable violations Yes No Needs Improvement c. Resolve probable violations Yes No Needs Improvement d. Routinely review progress of probable violations Yes No Needs Improvement e. Were applicable civil penalties outlined in correspondence with operator(s) Yes No Needs Improvement Evaluator Notes: D2. Yes. There appears to be a full circle process to ensure all compliance activities are taken care of. RI has a list of all compliance activities compiled throughout the year and they are filed on an annual basis. 3 Did the state issue compliance actions for all probable violations discovered? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: D3. Yes, through review of inspection records along with review of compliance activities it appears all violations are addressed appropriately. 4 Did compliance actions give reasonable due process to all parties? Including "show cause" hearing if necessary. Yes = 2 No = 0 Evaluator Notes: D4. Yes. Due process is given to all parties. 2 2 5 Is the program manager familiar with state process for imposing civil penalties? Were civil penalties considered for repeat violations (with severity consideration) or violations resulting in incidents/accidents? (describe any actions taken) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: D5. Yes, civil penalties considered and used. 2 2 6 Can the State demonstrate it is using their enforcement fining authority for pipeline safety violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: D6. Yes. There were 4 compliance actions that totaled $119,500 collected in 2015. 1 1 7 General Comments: Info Only = No Points Info Only Info Only DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 12#
RI NG Program Evaluation, 2015, page 13Evaluator Notes: regulations. D7. Yes. RIDPUC uses the full suite of regularity tools, including civil penalties, to achieve compliance with the Total points scored for this section: 15 Total possible points for this section: 15 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 13#
RI NG Program Evaluation, 2015, page 14PART E - Incident Investigations Points(MAX) Score 1 Does the state have written procedures to address state actions in the event of an incident/ accident? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: E1. Yes. See Procedure Manual, Section VI, pages 16-18. 2 2 2 Does state have adequate mechanism to receive and respond to operator reports of 2 2 incidents, including after-hours reports? And did state keep adequate records of Incident/ Accident notifications received? Chapter 6 Yes = 2 No = 0 Needs Improvement = 1 a. Acknowledgement of MOU between NTSB and PHMSA (Appendix D) Yes No Needs Improvement b. Acknowledgement of Federal/State Cooperation in case of incident/accident (Appendix E) Yes No Needs Improvement Evaluator Notes: E2. Yes. No issues 3 If onsite investigation was not made, did state obtain sufficient information from the 1 1 operator and/or by other means to determine the facts to support the decision to not go on-site? Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: E3. Yes. There was one incident in 2015 and it was investigated on-site. Most significant incidents and many minor incidents are responded to with an on-site visit. Procedures are in place to document any incidents that are telephonically investigated. 4 Were all incidents investigated, thoroughly documented, and with conclusions and 3 3 recommendations? Yes = 3 No = 0 Needs Improvement = 1-2 a. Observations and document review Yes No Needs Improvement b. Contributing Factors Yes No Needs Improvement c. Recommendations to prevent recurrences when appropriate Yes No Needs Improvement Evaluator Notes: E4. Yes. There was one incident in 2015 and it was investigated on-site. 5 Did the state initiate compliance action for violations found during any incident/accident investigation? Yes = 1 No = 0 Evaluator Notes: E5. NA. There was one incident in 2015 and it was investigated on-site. No violations were found. 1 NA 6 Did the state assist region office by taking appropriate follow-up actions related to the operator incident reports to ensure accuracy and final report has been received by PHMSA? (validate report data from operators concerning incidents/accidents and investigate discrepancies) Chapter 6 Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: 1 1 E6. Yes. RI is a good partner with the Eastern Region. No requests were received in 2015 concerning incidents. 7 Does state share lessons learned from incidents/accidents? (sharing information, such as: at NAPSR Region meetings, state seminars, etc) Yes = 1 No = 0 1 1 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 14#
RI NG Program Evaluation, 2015, page 15Evaluator Notes: E7. Yes. RI makes a detailed report during Region and NEPSR Meetings. 8 General Comments: Info Only = No Points Evaluator Notes: E8. Yes. RI has a robust plan for responding to incidents and usually makes on-site investigations. Info Only Info Only Total points scored for this section: 10 Total possible points for this section: 10 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 15#
RI NG Program Evaluation, 2015, page 16PART F - Damage Prevention Points(MAX) Score 1 Has the state reviewed directional drilling/boring procedures of each pipeline operator or 2 2 its contractor to determine if they include actions to protect their facilities from the dangers posed by drilling and other trench less technologies? NTSB Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F1. Yes, This item is reviewed with National Grid, the LDC serving RI, and it is in National Grid's Damage Prevention Program, Procedure 32. It has also been identified as a Risk in National Grid's DIMP. All sewer crow-bores have been identified and, in 2015, the home residents have been notified with a door hanger that explains the potential threat and advises a call to National Grid if there is any sewer blockage and National Grid will provide a free sewer inspection. 2 Did the state inspector check to assure the pipeline operator is following its written procedures pertaining to notification of excavation, marking, positive response and the availability and use of the one call system? Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F2. Yes. It is in the Std Insp Form, under Damage Prevention, 192.614(c)(1-6). 2 2 3 Did the state encourage and promote practices for reducing damages to all underground 2 2 facilities to its regulated companies? (i.e. such as promoting/adopting the CGA Best Practices encouraging adoption of the 9 Elements, etc.) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: F3. Yes. Don sits on the CGA Technology Committee in NAPSR. Lessons learned are shared in the annual M.U.S.T. (Managing Underground Safety Training) Meeting with operators and excavators. 4 Has the agency or another organization within the state collected data and evaluated trends on the number of pipeline damages per 1,000 locate requests? (This can include DIRT and other data shared and reviewed by the pipeline safety program) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: 2 2 F4. Yes. As in previous years, reviewed with National Grid and data is gathered and sorted by city for specifics. 5 General Comments: Info Only Info Only Info Only = No Points Evaluator Notes: F5. Damage Prevention is an item of specific focus in RIDPUC. Damage Prevention inspections and trainings are performed frequently in RI. RI is in the process of passing a law that demands a call to 911 in the event of a line hit that causes a gas release. Total points scored for this section: 8 Total possible points for this section: 8 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 16#
RI NG Program Evaluation, 2015, page 17PART G - Field Inspections Points(MAX) Score 1 Operator, Inspector, Location, Date and PHMSA Representative Info Only Info Only Info Only = No Points Name of Operator Inspected: National Grid opid 13480 Name of State Inspector(s) Observed: Don Ledversis, Gas Pipeline Safety Engineer Location of Inspection: 6th Avenue, East Greenwich, RI 02818, and Lincoln St, North Kingstown, RI 02852 Date of Inspection: September14, 2015 Name of PHMSA Representative: Patrick Gaume Evaluator Notes: G1. National Grid opid 13480, Don Ledversis, Gas Pipeline Safety Engineer, 6th Avenue, East Greenwich, RI 02818, and Lincoln St, North Kingstown, RI 02852; September14, 2015, Patrick Gaume 2 Was the operator or operator's representative notified and/or given the opportunity to be 1 1 present during inspection? Yes = 1 No = 0 Evaluator Notes: G2. Yes. Construction crews were at both sites. These were residential bare steel main replacements, with PE 2" pipe, at both locations. 3 Did the inspector use an appropriate inspection form/checklist and was the form/checklist used as a guide for the inspection? (New regulations shall be incorporated) Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: G3. Yes. These were day visit inspections using the RI State Gas Pipeline Construction Forms for plastic pipe. 4 Did the inspector thoroughly document results of the inspection? Yes = 2 No = 0 Needs Improvement = 1 2 2 Evaluator Notes: G4. Yes. Don worked through the entire checklist. The checklist was particularly applicable to the work being performed. 5 Did the inspector check to see if the operator had necessary equipment during inspection 1 1 to conduct tasks viewed? (Maps,pyrometer,soap spray,CGI,etc.) Yes = 1 No = 0 Evaluator Notes: G5. Yes. PPE, hand tools, excavation machine, electrofuse connection, plastic fuse alignment & cutting machine, plastic fusion heating tool, tape measure, and a fully rigged out truck; also fire extinguishers, site security, safety cones and tape, traffic controllers, and police officers. 6 Did the inspector adequately review the following during the field portion of the state evaluation? (check all that apply on list) Yes = 2 No = 0 Needs Improvement = 1 a. Procedures b. Records c. Field Activities d. Other (please comment) Evaluator Notes: G6. Yes, Field (construction) activity and records associated with the activity. DUNS: 623014990 2015 Gas State Program Evaluation 2 2 Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 17#
RI NG Program Evaluation, 2015, page 187 Did the inspector have adequate knowledge of the pipeline safety program and regulations? (Evaluator will document reasons if unacceptable) Yes = 2 No = 0 Needs Improvement = 1 Evaluator Notes: G7. Yes. Don exhibited a professional level of knowledge for the inspections I observed. 2 2 8 Did the inspector conduct an exit interview? (If inspection is not totally complete the 1 1 interview should be based on areas covered during time of field evaluation) Yes = 1 No = 0 Evaluator Notes: G8. Yes. Don reviewed what was expected for the job and the crew demonstrated that they had full knowledge of what was expected for the job. No Violations found. 9 During the exit interview, did the inspector identify probable violations found during the 1 1 inspections? (if applicable) Yes = 1 No = 0 Evaluator Notes: G9. Yes. Don reviewed what was expected for the job and the crew demonstrated that they had full knowledge of what was expected for the job. No Violations found. 10 General Comments: 1) What did the inspector observe in the field? (Narrative description of field observations and how inspector performed) 2) Best Practices to Share with Other States - (Field - could be from operator visited or state inspector practices) 3) Other. Info Only = No Points a. Abandonment b. Abnormal Operations c. Break-Out Tanks d. Compressor or Pump Stations e. Change in Class Location f. Casings g. Cathodic Protection h. Cast-iron Replacement i. Damage Prevention j. Deactivation k. Emergency Procedures l. Inspection of Right-of-Way m. Line Markers n. Liaison with Public Officials o. Leak Surveys p. MOP q. MAOP r. Moving Pipe s. New Construction t. Navigable Waterway Crossings u. Odorization v. Overpressure Safety Devices w. Plastic Pipe Installation x. Public Education y. Purging z. Prevention of Accidental Ignition A. Repairs B. Signs Info Only Info Only DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 18#
RI NG Program Evaluation, 2015, page 19C. Tapping D. Valve Maintenance E. Vault Maintenance F. Welding G. OQ - Operator Qualification H. Compliance Follow-up I. Atmospheric Corrosion J. Other Evaluator Notes: G10. These were residential bare steel main replacements, with PE 2" pipe, at both locations. It appeared that the jobs were being performed by highly professional crews with all materials and equipment readily available. Total points scored for this section: 12 Total possible points for this section: 12 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 19#
RI NG Program Evaluation, 2015, page 20PART H - Interstate Agent State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with "PHMSA directed inspection plan"? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 3 Did the state submit documentation of the inspections within 60 days as stated in its latest Interstate Agent Agreement form? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 4 Were probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 5 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 6 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 7 Did the state initially submit documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: H1-8. NA Not an Interstate Agent. 1 NA 8 General Comments: Info Only = No Points Evaluator Notes: H1-8. NA Not an Interstate Agent. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 20#
RI NG Program Evaluation, 2015, page 21PART I - 60106 Agreement State (If Applicable) Points(MAX) Score 1 Did the state use the current federal inspection form(s)? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 2 Are results documented demonstrating inspection units were reviewed in accordance with state inspection plan? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 3 Were any probable violations identified by state referred to PHMSA for compliance? (NOTE: PHMSA representative has discretion to delete question or adjust points, as appropriate, based on number of probable violations; any change requires written explanation.) Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 4 Did the state immediately report to PHMSA conditions which may pose an imminent safety hazard to the public or to the environment? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 5 Did the state give written notice to PHMSA within 60 days of all probable violations found? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 6 Did the state initially submit adequate documentation to support compliance action by PHMSA on probable violations? Yes = 1 No = 0 Needs Improvement = .5 Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. 1 NA 7 General Comments: Info Only = No Points Evaluator Notes: I1-7. NA Not a 60106 agreement State Partner. Info Only Info Only Total points scored for this section: 0 Total possible points for this section: 0 DUNS: 623014990 2015 Gas State Program Evaluation Rhode Island RHODE ISLAND DIVISION OF PUBLIC UTILITIES AND CARRIERS, Page: 21#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.